Switching ChannelsWildlife trade routesinto Europe and the UK

A WWF/TRAFFIC Report

December 2002

All rights reserved. All material appearingin this publication is subject to copyrightand may be reproduced with permission.Any reproduction in full or in part of thispublication must credit WWF-UK as thecopyright holder.

The authors have used all reasonableendeavours to ensure that the content of thisreport, the data compiled, and the methodsof calculation and research are consistentwith normally accepted standards andpractices. However, no warranty is givento that effect nor any liability accepted bythe authors for any loss or damage arisingfrom the use of this report by WWF-UKor by any other party.

The views of the authors expressed in thispublication do not necessarily reflect thoseof WWF or TRAFFIC.

ACKNOWLEDGEMENTS

This report was compiled by DavidCowdrey, based on an independentresearch report produced by The Universityof Wolverhampton which wascommissioned by WWF and TRAFFIC –the wildlife trade monitoring network.

We gratefully acknowledge: MartinRoberts, Dee Cook and Jason Lowther,Regional Research Institute,University of Wolverhamptonwww.wlv.ac.uk

Thanks are also due to Kirsty Clough,WWF Campaign Coordinator;TRAFFIC International – especiallyStephanie Pendry and Crawford Allan;TRAFFIC Europe, particularly CarolineRaymakers; HM Customs and Excise– especially Chris Miller for his patience inhelping disentangle the seizure records; and

Andy Fisher of the Metropolitan Police.John Sellar, Senior Enforcement Officerat CITES Secretariat, provided a usefulcritique of aspects of the report andvaluable access to a provisional draft ofthe Secretariat’s own views on enforcementand intelligence issues. The authors wouldalso like to thank the Global WildlifeDivision at DEFRA for allowing accessto previous research conducted byWolverhampton University.

TRAFFIC, the wildlife trade monitoringnetwork, works to ensure that trade in wildplants and animals is not a threat to theconservation of nature. It works incooperation with the Secretariat of theConvention on International Trade inEndangered Species of Wild Fauna andFlora (CITES).

TRAFFIC is a joint programme of WWFand IUCN The World Conservation Union.

TRAFFIC International219 Huntingdon RoadCambridge CB3 0DLTelephone: +44 (0)1223 277 427Fax: +44 (0)1223 277 237www.traffic.org

For further information please contact:

The Species ProgrammeWWF-UKPanda House, Weyside ParkGodalming, Surrey GU7 1XRTelephone: +44 (0)1483 426444Fax: +44 (0)1483 426409www.wwf.org.uk

© WWF-UK, 2002 Panda symbol © WWF 1986® WWF Registered Trademark Registered Charity No 1081247TRAFFIC International registered charity number 1076722® TRAFFIC registered trademark

Contents

Acknowledgements 2

Introduction 4

The size of the legal trade in wildlife 4

Methods employed in illegal wildlife trade 4

Source countries: processing and transit 6

Global trade routes 6

European markets 8

Examples of trade routes to the UK and Europe 8

Illegal trade flowing into the UK 11

Market disruption in the UK – uncovering the illegal trade 14

Recommendations 15

4 Switching Channels

INTRODUCTION

Illegal wildlife trade routes are difficult to uncover. By their very nature they are covert,sometimes run by organised criminals, and often used to smuggle other commodities such asdrugs and guns. This report attempts to uncover some of these complex trade routes into Europeand the UK, as well as the techniques used to smuggle wildlife. It is based on researchcommissioned by WWF and TRAFFIC, the wildlife trade monitoring network, andindependently conducted by the University of Wolverhampton which uses evidence from HMCustoms and Excise, the Police and a number of court cases.

THE SIZE OF THE LEGAL TRADE IN WILDLIFE

It must be remembered that there is a huge legal market for wild plants and animals – a marketwhich the illegal trade undercuts, supplants and exploits. Unscrupulous individuals, roguetraders and criminal gangs all threaten sustainable and responsible businesses that provide vitalincome to some of the world’s poorest countries.

The global legal trade in wildlife resources was estimated in the early 1990s to be worth nearlyUS$159 billion a year in export value. Sixty five per cent of this trade involves timber exports(worth US$104 billion), with fisheries exports constituting a further 25 per cent (US$40 billion).Trade in live animals, plants, products and derivatives was therefore estimated to be worthapproximately US$15 billion annually.

The legal trade in protected species broadly flows from range areas – where the species comefrom – to consumer areas. Some are both significant consumer and range areas. The situation ismade more complex by a thriving trade in captive-bred or artificially propagated specimens,which may be farmed in non-range areas and traded internationally. The involvement ofintermediate destinations and the consequent re-export trade further complicates the picture andopens up opportunities for illegal trade.

METHODS EMPLOYED IN ILLEGAL WILDLIFE TRADE

Criminals who engage in the illegal wildlife trade are often merely transferring the skills,connections, transport routes, counterfeiting and concealment techniques they have developed inthe areas of drugs, small arms or human trafficking.

The skills used by these people will depend on the type of illegal shipment, which may containlive animals or plants, dead animals or unprocessed parts (e.g. taxidermy specimens, skins,tusks, bones, trophies), dead plants or parts (e.g. dried flowers, ginseng roots, fibres) andprocessed or worked parts (e.g. carved ivory, traditional Asian medicine ingredients, tannedskins, sawn timber).

Intermediate destinations

Illegal trade in wildlife is often not conducted directly between range area and consumer area,but specimens may be transported to a variety of intermediate destinations. As with many typesof international trade, intermediate destinations are a common feature of illegal wildlife traderoutes and can serve five broad functions:

Switching Channels 5

1 “funnel” locations where shipments are bulked for longer-haul journeys;

2 stopovers and convenient ports – these may be ports where illegal wildlife shipments areswitched between different modes of transport. For instance, shipments might be switchedbetween surface and air transport;

3 processing centres – where products made from wildlife are manufactured;

4 transhipment centres and “free” trade areas – countries where porous borders, weaklegislation and lax enforcement allow the illegal import and export of wildlife to continueunhindered, and provide suitable transhipment locations for wildlife trafficking1;

5 regional distribution centres – these are close to final destinations and provide places wherebulk shipments are broken down into smaller consignments and transported on to theconsumer market.

Techniques used to avoid Customs

Like other smugglers, wildlife traffickers go to great lengths to cover their tracks and concealtheir offences. They do this in a number of ways, but usually employ three general techniques:

1 disguising illegal items so that they will pass through customs checks as legal imports.This involves either changing the appearance of the items, or providing fraudulentdocumentation, or both;

2 concealing the illegal items within legal shipments;

3 evading customs controls by making wholly illegal shipments;

Other methods may be more blatant – such as shipping to locations where open sale of theseitems is not illegal or where enforcement is particularly weak.

The following examples illustrate the lengths to which smugglers will go in order to concealshipments:

• ivory has been dyed to appear like wood and concealed in timber shipments;

• rare bird chicks have been mixed with shipments of hen chicks from India;

• a rhino horn was hidden inside a statue made from plaster of Paris.

Wholly illegal shipments to the UK include the example of Raymond Humphrey and hisco-conspirators, who took birds of prey from Thailand, concealed them in suitcases and flewthem direct from Thailand to the UK.

1 These areas may also become processing centres, where manufacturers take advantage of the freedom of movement

of raw materials and finished products, and the ready access to markets where the finished products may be passed off

as legal.

6 Switching Channels

SOURCE COUNTRIES: PROCESSING AND TRANSIT

Skin, fur and fleece products and traditional Asian medicines (TAMs) – including parts ofendangered reptiles, tiger, rhino, antelope and bear – are manufactured from raw materials thatare gathered from a range of countries, and transported to processing centres where manufacturetakes place. Finished products will be shipped on in bulk after processing. Some examplesof processing and transit include reptile skins and shahtoosh products.

• Reptile skins must be tanned, cut and manufactured into products such as watch straps andhandbags. This results in flows of untanned skins into Europe, where tanneries are located.They are then re-exported to plants in other countries for cutting and manufacture. Themultiple re-export and changing size and appearance of the skins has often been exploitedto launder illegally obtained skins in with legal shipments. The finished products are thenre-exported to Europe for sale.

• Traditional Asian medicine manufacturers operating in the Far East gather shipmentsof endangered species or their parts and derivatives from all over the world, including tigerbones from India, bear gall bladders from Asia and North America, and musk deer glandsand ginseng from China and Russia. The packaged medicines are distributed within Far Eastmarkets, and to Europe and North America through commercial shipments and smallquantities carried by passengers.

• Manufacture of shahtoosh shawls in India, made from Tibetan antelope fleeces, aretransported from the range areas in China to the north of the country. Finished articlesare distributed to consumer markets in Asia, Europe, North America and the Far East.

GLOBAL TRADE ROUTES

Between 1997 and 1999, the UK accounted for 12 per cent of all European Union (EU) exportsand re-exports of permitted consignments of CITES2 and European Community (EC)3 listedspecies. Research shows that the principal destination was Asia – which was also the largestsource of imports and a key range area. This not only illustrates the importance of the UK in thechain of trade in protected species, but also signals the potential opportunities for illegal trade toexploit networks and routes used by the legal trade.

Historically, the most significant transhipment centres for the illegal wildlife trade have beenHong Kong and Singapore. However, recent research points to the United Arab Emirates (UAE)as a centre of growing importance. The UAE as a nation state has joined CITES, but partlybecause each emirate in the federation maintains a separate enforcement policy, the record ofthe UAE overall has been very poor in terms of compliance with, and enforcement of, CITES.There is a bustling free trade zone in the Dubai emirate, and the Blue Souk in Sharjah isnotorious as a market where endangered species are openly on sale. In a recent response toenquiries regarding the open sale of skins of tigers and other CITES-listed species, a DubaiEconomic Development spokesman said:

2 Convention on International Trade in Endangered Species of Wild Fauna and Flora3 The principal EC regulation seeks to govern the trade in species of fauna and flora or derivatives listed in four Annexes

(A-D).

Switching Channels 7

“Currently the sale of any type of skin is allowed to take place in UAE, whetherthey come from cows or tigers. The fact that the skins were illegally smuggledfrom the original country and then brought illegally into the UAE is not ourconcern. International trade may be illegal, but actually selling them here is not.”

In November 2001, the CITES Secretariat stated it had “discovered that much of the caviarworth $25 million that left the UAE during the first 10 months of this year appeared to be ofunlawful origin”. At the same time, there is evidence that the UAE may be used as a centre formoney laundering and that it may be becoming a transhipment centre for heroin. Once again,the potential for links between the global illegal wildlife trade and the drugs trade are clear.Much of the caviar was destined for markets in Europe and the US.

Figure 1. Caviar trafficking to EU and US markets through UAE

In 2001 the prosecution of US Caviar & Caviar in the US demonstrated the involvement of anAmerican labelling firm located in the UAE and applying counterfeit labels to illegallyharvested caviar. There is mounting evidence that caviar traders operating in the UAE areincreasingly involved in the illegal trade.

Wildlife smuggling can also be a response to other desires and markets, as in the case of illegalhunting. In November 2001, following a lengthy undercover investigation, the US Fish andWildlife Service prosecuted five people in Missouri for smuggling endangered leopards andtigers into the US so that they could be hunted and killed. Similar undercover operations inIndia have revealed that hunters will pay vast sums to hunt and kill endangered species such astigers, Tibetan antelope, brown bears and clouded leopards. In another recent US court case in

8 Switching Channels

May 2002, eight men were indicted on charges which included killing and trading tigers andleopards and selling the meat for human consumption.

EUROPEAN MARKETS

Western Europe is an important market for the trade in protected species. UNEP-WCMC datafor the western EU countries demonstrates that between 1997 and 1999, the EU imported22,878 permitted consignments of CITES-listed species and products (of these, 11 per cent wereimported into the UK), and exported 15,646 consignments – a net import of around 2-3,000consignments a year, when each shipment may contain tens of thousands of items or just a fewspecimens. This signals the importance of the EU both as a market and an intermediatedestination for wildlife products.

The UK plays an important role in the wildlife trade as both a consumer and a re-exporting(intermediate) country. The main sources of imports into the UK are range areas in Africa andAsia – as they are for the EU as a whole.

The US is the largest exporter of consignments to the EU, and while some of the speciesinvolved are native to that country, most are not. In some cases, exports of non-native speciesfrom the US represent intermediate or transit trade from other range areas (for instance,numerous parrot species are imported from Central and South America). It should be noted thatsome trans-Atlantic shipments consist of captive-bred or artificially propagated specimens forsale in Europe.

Indonesia is the second largest exporter of consignments to the EU, and many of the speciesexported are native to Indonesia itself. Hence much of this trade is direct from state of origin tothe destination market.

EXAMPLES OF TRADE ROUTES TO THE UK AND EUROPE

The trade in controlled species into Europe is helped by well-developed ports and cargohandling capabilities, as well as high volumes of international trade in general commodities.This is reflected in the role of countries such as the US and South Africa as exporters of CITES-listed consignments to the EU and the UK. In addition, almost all trade to Switzerland and theCzech Republic is likely to be intermediate or transit: because of these countries’ land borderswith the EU, there are many opportunities to smuggle illegally traded wildlife into the EU.

Some states shipping significant numbers of permitted CITES consignments into the EU mayhave particular connections with EU countries for a range of reasons – former colonial rule,common languages, currencies and, in some cases, favourable trade arrangements. For instance,Suriname is a former colony of the Netherlands, and the two countries maintain a special tradingrelationship with less stringent import controls – between 1997 and 1999, 31 per cent ofSuriname’s exports of wildlife to the EU arrived at Dutch ports. The fact that the Netherlandsalso had the highest number of wildlife shipments in the EU during this period stresses theleading role played by that country in the export and re-export of protected wildlife, andsuggests that it could be a major illegal import destination into the EU.

Switching Channels 9

Trade routes are developed not only by the opportunism of illegal wildlife traders who exploitloopholes, weak enforcement procedures and changing local enforcement efforts or priorities,but also, in some cases, through detailed intelligence. The following examples of illegal tradelook at the sometimes complex routes taken from range areas to intermediate and consumerareas, much of which is destined for markets in the EU and the UK:

• Hummingbirds from South American countries have been smuggled to Suriname acrosspoorly controlled land borders, or by coastal or river transport. From Suriname, shipmentsproceed to the Netherlands. Bird traders may then purchase these birds and take them intothe UK.

• A trader smuggling birds from Guyana used a tortuous route involving several stopovers(see Figure 2). The birds were taken by boat to Grenada – sometimes via Suriname – wherethe trader owned a zoo, effectively laundering them into the legal market. They were thenmoved to Barbados and flown to Havana, then on to Moscow and Hungary, from where thebirds were transported overland into western European markets. The same trader wasthought to use another route from Moscow to Singapore, where he would pick up blackcockatoos from Indonesia and smuggle them back to the West Indies.

Figure 2. Guyana to the EU – a tortuous trade route for smuggling exotic birds

10 Switching Channels

• Nicolaas Peters, a Dutch national, had been involved in trading wildlife specimens aroundthe world for 18 years, mainly for the taxidermy trade. Although based in Wales, his mainwildlife trading centres were in Belgium and the Netherlands. He had a string of convictionsfor wildlife trade offences, including fines in Germany for trading without permits, inEngland for the illegal possession of protected wildlife, in France for smuggling wildlifeand in Australia for smuggling dead birds and insects. Following a tip-off from ataxidermist, HM Customs and Excise (HM C&E) raided Peters’ house with wildlifeinvestigators from TRAFFIC and the RSPB, and discovered more than 700 dead specimensincluding many highly endangered species. Three hundred bird specimens had originatedfrom the Philippines and included at least 42 CITES-listed species. Other seized itemsincluded a Siberian tiger skull, a Philippine eagle skull and a ring-tailed lemur – all fullyprotected under CITES.

Figure 3. The global extent of Peters’ UK-based illegal wildlife trade

A further raid in Belgium found a larger stockpile of specimens. Papers discovered at Peters’home revealed his involvement in organising the killing and smuggling of birds from thePhilippines, and the identity of an official to be bribed. Peters had also exported manyspecimens to the US, either without licence or under licences issued in Belgium, which he re-used illegally. The global reach of Peters’ operation is illustrated in Figure 3 above, and it isclear that he used Belgium as his major port of entry into the EU because he considered therewas less risk of detecting the smuggling of goods into Belgium than directly into the UK. Oncethe wildlife had illegally entered the EU, he was able to transport it throughout the EU virtuallyunhindered.

Switching Channels 11

ILLEGAL TRADE FLOWING INTO THE UK

By definition, the hidden nature of wildlife trafficking makes it difficult to establish the fullextent and patterns of illegal trade flows into the UK, but we can get an indication of thisthrough looking at customs seizures of wildlife goods. HM C&E maintains records of seizuresof all CITES and EC-listed species where illegal consignments are detected at UK ports.A breakdown of seizures over the period 1996 to 2000 shows that seizures have remained fairlyconstant, despite changes in Customs staffing and priorities over this time. Further, an analysisof the regions from which consignments are shipped to the UK demonstrates similarities withthe pattern of permitted imports.

Figure 4. HM C&E seizures at customs stations for the ten stations with most seizures, 1996-20004

4 Source: HM C&E. Customs ‘stations’ are not always strictly ports – for instance, Waterloo International has a customs

station for travellers arriving on Eurostar who have travelled from outside the EU, but Waterloo is not a port. Note that

the figure for seizures at Heathrow includes 610 instances where the seizure location is recorded as ‘London Airports’,

the great majority of which are attributable to Heathrow. Note also that seizures at Lerwick consist in the main of small

quantities of goods seized during searches of east European fishing vessels.

12 Switching Channels

Heathrow airport is by far the most frequent location for wildlife seizures, followed byManchester and Gatwick airports. These patterns not only reflect the routes of the illegal tradeand entry points used by wildlife smugglers, but also the numbers (and priorities) of HM C&Estaff at those ports. They also reflect the effort and expertise of Customs staff at Heathrow.It should be noted that these seizures are achieved despite the higher organisational prioritieswhich HM C&E is mandated to work to, including drug smuggling and duty-bearing productssuch as alcohol and tobacco.

Seizures and inspection by Customs officers can only be conducted where border controls are inplace. The permeability of borders within the EU means that illegal trade also enters the UKthrough member states with little or no monitoring. To address the challenges of the illegalwildlife trade effectively, it is essential to consider the ways in which the legal global tradeis regulated across and within national borders. The EU has established a single market amongits member states, based on principles of free circulation of goods, people, services and capital.In order to achieve this, a framework, in the form of a customs union operational from March1993, was developed so that common rules exist at its internal borders.

Table 1. Seizures of illegally imported CITES/EC-listed species at UK ports by HM C&E, 1996-2000

Year Total

1996 442

1997 495

1998 497

1999 336

2000 441

Total 2,211

Numbers of smuggled consignments tell only part of the story. Numbers of items within thoseconsignments, and the species they comprise, need further investigation. A recent analysis ofseizure records for 1999 and 2000 helps clarify some of these points and indicates that:

• approximately 17 per cent of seizures were of live animal specimens;

• dead items, ranging from taxidermy specimens to traditional Asian medicine pills,made up 75 per cent of seizures;

• only 7 per cent of seizures were of plants, the majority of which were rare orchidswhich sometimes arrived in large shipments from Taiwan;

• nearly half – 47 per cent – of all live animal specimens seized were reptiles,reflecting their popularity as exotic pets and the ease of transporting them;

• parrots and macaws made up 18 per cent of live animal seizures;

• 60 per cent of live animal seizures could be categorised as small consignments, representingeither the smuggling of a few valuable specimens, or tourists returning with pets purchasedabroad – in the latter case often from Morocco and usually tortoises. Other small seizuresrepresented the undeclared excess numbers in shipments where the number of specimenswas under-declared;

Switching Channels 13

• TAMs represented 26 per cent of dead item seizures, often consisting of packaged pillsand plasters, but also arriving as ingredients – American ginseng was commonly seizedin consignments from the US, while 84 per cent of seizures of consignments arriving fromChina contained TAMs;

• goods manufactured from reptile skins (mainly watch straps and wallets) constituted 17 percent of dead item seizures, and were often imported from Switzerland, the US or Nigeria;

• dead corals and seashells (usually conch) made up 21 per cent of dead item seizures butwere almost always found in small quantities, reflecting the frequency with which touristsbring back items such as these as souvenirs;

• of the 32 incidents of caviar seizure, the 12 direct shipments from Russia and Iran (bothrange areas) were mainly of large consignments; six illegal shipments from Dubai (partof the UAE) illustrate the UK’s role as a market for caviar trafficked through the UAE;

• the number of ivory seizures was small (36 in total), in part reflecting the successfulsuppression of ivory trading into the UK. The seizures consisted of raw ivory (10) arrivingmainly from African exporters, and worked ivory (26) from a mixture of range and non-range areas, including Indonesia and the US.

The five countries that consigned most shipments of endangered wildlife to the UK in 1999 and2000 are listed in Table 2 below. What is clear from this table is the preponderance of liveshipments from the US, where few endangered species are native, reflecting the substantialtrade in captive-bred specimens that finds markets in Europe. The role of another non-rangestate – Switzerland – in relation to dead items is in part attributable to the large numbersof reptile skins (some as watchstraps) that are exported from Switzerland to the EU, but thefigures also help confirm Switzerland’s role as an entry point into the EU and a stepping-stoneto UK markets.

Table 2. Numbers of seizures at UK ports by type of seizure, 1999-2000

Country LiveAnimals

Country DeadItems

Country Plants

US 21 China / HongKongcombined

117 US 8

Morocco 13 US 71 Malaysia 8

Indonesia 6 Switzerland 21 Taiwan 7

Singapore 5 Thailand 20 Ecuador 5

Ghana /Lebanon (=)

4 Jamaica 17 Australia 3

14 Switching Channels

While aircraft are the predominant mode of transport used, it should also be remembered thatmany illegal wildlife shipments entering the UK are made by surface means, and by postaldistribution systems. The figures for international postal depots show 123 seizures at theprincipal air mail sorting depot at Coventry.

Table 3. Number of seizures at international postal depots 1996-2000

Depot No. of seizures

Coventry International Hub 123

Mount Pleasant Parcel Post Depot 37

Dover Parcel Post Depot 21

MARKET DISRUPTION IN THE UK – UNCOVERING THE ILLEGAL TRADE

The work of the new National Wildlife Crime Intelligence Unit within the National CriminalIntelligence Service will undoubtedly contribute to the effectiveness of the UK’s enforcementefforts and could, through Europol and Interpol collaborations, play a significant part in EU-wide efforts to disrupt the illegal wildlife trade. However, with more countries hoping to accedeto the EU (they are generally less affluent than current members and are often existing orpotential transit states for the illegal wildlife trade) and other agreements that give certain statespreferential access to the EU single market, there is an urgent need for more effective internalcontrols to combat the illegal wildlife trade. The need for effective EU-wide enforcementcapacity will become even more urgent if the recently indicated willingness of the EU to joinCITES as an entity is carried forward.

Illegal markets, at national levels, can also be interrupted by concerted enforcement action. Forinstance, in February 1995 the Metropolitan Police (together with forces in Birmingham andManchester) launched Operation Charm, and raided Chinese pharmacies to follow up evidenceobtained in an investigation by TRAFFIC International. As a result, several thousand illegalmedicine products were seized, together with body parts of tiger, rhino, bear and other species.Although these seizures were felt to have had a clear impact on the illegal trade, the markets forthese products still drive the supply, and Operation Charm has become a continuing initiativewith wider aims to combat many aspects of the illegal trade. These include seeking to raise thelevel of public awareness about the illegal trade in endangered species.

Switching Channels 15

RECOMMENDATIONS

1 In the UK, HM Customs and Excise should give a higher priority to detecting andpreventing wildlife trafficking, taking into account both the inherent seriousness of theensuing environmental damage, and the evident linkages to the drugs trade. Similarly,higher priority should be given to the detection and disruption of illegal trading withinthe UK by police forces.

2 In the UK, changes need to be made to the law, by increasing penalties from two to fiveyears imprisonment which will automatically make wildlife trade offences arrestable.

3 In the UK, sentencing guidelines should be developed and provided to the judiciary, andadditional training should be given to both prosecutors and the judiciary to increase theirawareness of the impact of the illegal wildlife trade.

4 More effective cooperation should be promoted with the EU Customs Union, through jointtraining and exchange and placement schemes, which should be facilitated by the EuropeanCommission and the World Customs Organisation.

5 Data, intelligence and best practice should be shared among relevant statutory and otherbodies, including non-governmental organisations.

6 A common methodology/framework for assessing the value and seriousness of wildlifetrafficking should be developed across CITES signatories.

7 The National Wildlife Crime Intelligence Unit (NWCIU) can play a vital role in providingintelligence to assist Customs in the following:

· Development of effective and regular risk assessments and targetingprocedures.This will ensure that Customs receive early indications of any switching of channelsto other ports of entry and other trade routes.

· Generation of intelligence packages for Customs. For this to be most effective,a Customs officer should be seconded to work within the Unit and act as a liaisonpoint with Customs.

· Greater co-operation and collaboration with enforcement agencies internationally,facilitated through the NWCIU. Customs could establish useful bilateral and multilateralco-operation with source and transit states to tackle the problemsat source, as well as the interception at UK ports.